The failure of the recent attempt to impeach the late Governor Horton of Tennessee is of particular interest to students of political science because of the grounds upon which the failure to impeach was justified. The main reason given by many members of the legislature was a constitutional one, namely, that an officer cannot be impeached during his second term of office for high crimes and misdemeanors committed during his first term. Considerable doubt remains as to the soundness of this position, many people thinking that the explanation given was a clever excuse but one that would not justify the failure to impeach. It is interesting, therefore, to ascertain if, in impeachment trials where this point has arisen, a similar position has been taken either by legislative bodies or by the courts.